FSSAI warning labels: Food regulation used to have a fairly simple test: is the product safe to eat? That is no longer enough. A packet can meet safety standards and still leave consumers with a false idea of what they are buying. Claims such as “healthy”, “natural”, “high protein” or “pure”, along with carefully chosen images and colours, can give an ordinary processed food a health halo it may not deserve.
India is now being forced to confront this problem. On September 10, the Supreme Court examined the Food Safety and Standards Authority of India’s proposed front-of-pack warning system and asked pointed questions about its thresholds, design and implementation timetable. FSSAI has proposed red warning labels for packaged foods high in specified nutrients of concern. The proposal is yet to become the final rule.
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The case gets to the heart of modern food regulation. Consumers should not need a degree in nutrition science to work out whether the impression created on the front of a packet bears any relation to what is inside.
FSSAI rules depend on state enforcement
FSSAI’s role is often misunderstood. It sets national food standards and regulates areas such as labelling, claims, licensing and food categories. Much of the day-to-day enforcement, however, rests with state food-safety authorities. The Food Safety and Standards Act requires states to appoint Commissioners of Food Safety, while Food Safety Officers inspect businesses, take samples and initiate enforcement proceedings.
That division of responsibility makes sense in a country of India’s size. It also produces uneven outcomes. The quality of enforcement depends on the number of inspectors available, laboratory capacity and the willingness of state administrations to pursue violations. Better regulations issued in Delhi cannot by themselves ensure better food safety in every district.
The distinction matters because the food market has changed faster than the enforcement machinery. Packaged foods, quick commerce, restaurant aggregators, nutraceuticals and online marketplaces have created products and distribution channels that did not exist on anything like today’s scale when the basic regulatory architecture was designed.
Consumers themselves are therefore becoming part of the surveillance system. In April 2025, FSSAI introduced a facility allowing people to report misleading claims on packaged food through Food Safety Connect and FoSCoS. Consumers can submit photographs of the front of the pack, licence details and, where relevant, the e-commerce link. The complaint system can then route cases to food businesses and state authorities.
That greatly expands the regulator’s field of vision. It does not turn every complaint into proof of an offence. A photograph on social media can raise a legitimate question, but regulatory action still needs an identifiable product and evidence capable of being tested. Otherwise consumer vigilance can deteriorate into trial by viral post.
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The front of the packet is an advertisement
The harder question concerns labelling. Consumers do not encounter a food product as a laboratory report. They encounter a packet designed by marketers.
The ingredient list and nutrition table may be accurate while the overall impression on the front is much less so. Pictures, product names and health-related expressions influence the purchase before most consumers reach the fine print.
FSSAI’s Advertising and Claims Regulations already require claims to be truthful, unambiguous, meaningful and non-misleading. The regulator has shown that it is prepared to apply that principle broadly. In May 2025 it advised food companies to discontinue the term “100%” on labels and promotional material, arguing that the expression could create a misleading impression of purity or superiority.
The regulatory principle should therefore be straightforward. An accurate ingredient list on the back cannot be a licence to create a materially different impression on the front.
This is where front-of-pack nutrition labelling becomes important. India has debated such a system for years. FSSAI’s 2022 draft proposed an Indian Nutrition Rating based on stars. The process subsequently became bogged down in consultation and disagreement. The Supreme Court has since pressed the authorities for a clearer warning system.
FSSAI’s latest proposal marks a substantial shift. It has told the Court that it proposes red hexagonal warnings indicating “high fat”, “high sugar” or “high salt” for products crossing specified thresholds. Its first phase would apply the warning where two or more nutrients of concern exceed the threshold, as well as to specified sweetened beverages; a second phase would extend it to products high in any one nutrient. The Court has asked why the distinction is necessary and has sought greater clarity on the timetable and design.
Those questions deserve answers. A warning label has little value if its thresholds are so complicated that consumers cannot understand what it means, or if products high in one troublesome nutrient escape the first round of warnings. At the same time, regulators need defensible thresholds and sensible exemptions. Foods cannot be classified solely by the emotional force of a red symbol.
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Nutraceuticals need a higher bar
The problem becomes sharper with nutraceuticals and health supplements. These products inhabit an awkward commercial space. They are sold as foods, but their marketing can come close to the language consumers associate with medicines.
Indian regulation already recognises the risk. Nutraceutical labels must carry information on recommended usage and prominent warnings such as “NOT FOR MEDICINAL USE”. The rules also prohibit claims that such products prevent, treat or cure human disease.
The legal distinction is clear on paper. The commercial distinction can be less obvious when a product promises immunity, better digestion, improved energy or other physiological benefits. The closer the sales pitch moves towards therapeutic territory, the stronger the case for scrutiny of both the wording and the evidence supporting it.
This is one reason regulation cannot concentrate only on what appears in the ingredients panel. The claims surrounding the product matter just as much.
Quick commerce cannot be a regulatory hiding place
E-commerce further complicates accountability. The old chain from manufacturer to distributor to neighbourhood retailer has acquired another layer. A consumer may discover a product through an app, read its claims there, place the order through the platform and receive it from a warehouse operated by another entity.
The platform cannot simply disappear from the regulatory picture.
FSSAI already treats e-commerce entities dealing in food as food business operators for regulatory purposes. Its rules require them to prevent misleading information and false claims on their platforms. A December 2024 advisory went further, requiring online product claims to correspond with the physical label and telling platforms to have mechanisms to ensure that listed products comply with labelling rules.
That is particularly important for health supplements and aggressively marketed packaged foods. The online listing is often the only label a customer studies before buying. If the marketplace reproduces or amplifies an exaggerated claim, the distinction between seller and intermediary becomes much less persuasive from the consumer’s point of view.
The aim should not be to make platforms responsible for every defect in every packet. They should, however, be accountable for information presented on their own screens and for basic due diligence on sellers using their marketplaces.
Warning labels should make choice easier
India now has an opportunity to settle one of its longest-running food-labelling debates. The Supreme Court has forced movement after years in which the proposed front-of-pack system remained unfinished. FSSAI’s red-warning proposal is a significant advance, but the details will determine whether it works.
Industry objections cannot simply be dismissed. Thresholds need scientific justification. Regulators must decide how to treat foods that naturally contain significant quantities of fat or sugar, how processed products should be classified and whether the same rules can sensibly cover very different categories. The Supreme Court itself has raised several of these issues.
But complexity is an argument for designing a good label, not for leaving consumers with the present system.
A front-of-pack warning will not tell an individual what to eat for breakfast or whether a particular food fits a balanced diet. It should do something more modest and more useful: tell a shopper, in a few seconds, when a packaged product contains unusually high quantities of nutrients that deserve attention.
That is the standard by which the next stage of FSSAI regulation should be judged. The number of notices issued or raids conducted tells only part of the story. Good regulation should make deception difficult before a product reaches the shopping basket. For packaged food, that begins with ensuring that the front of the packet is at least as truthful as the fine print on the back.